`Contractors
`
`Submission Date: 1/28/2019 12:46:35 PM
`
`Filed Date: 1/28/2019 12:46:35 PM
`
`Dockets
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`EL1937000 Complaint and Declaratory Order
`
`Filing Party/Contacts:
`
`Filing Party Signer (Representative)
`Other Contact (Principal)
`
`
`State Water Contractors mrp@dwgp.com
`lmk@dwgp.com
`State Water Contractors bkm@dwgp.com
`thaines@swc.org
`State Water Contractors
`smorris@swc.org
`
`Basis for Intervening:
`State Water Contractors (â(cid:128)(cid:156)SWC â(cid:128)(cid:157)) is a nonprofit, mutual benefit corporation
`organized under the laws of the State of California. SWC is comprised of 27
`public agencies holding contracts with the State of California Department of
`Water Resources to purchase water delivered by the State Water Resources
`Development System, otherwise known as the State Water Project (â(cid:128)(cid:156)SWP â(cid:128)(cid:157)).
`Collectively, these public agencies supply water for drinking, commercial,
`industrial, and agricultural purposes to a population of more than 26 million
`and to over 750,000 acres of farmland and businesses in northern, central and
`southern California. SWC was formed to further the common interest of its
`members with respect to the operation and administration of the SWP. SWC
`represents the interests and views of their members regarding the SWP before
`state and federal legislative bodies and administrative agencies, including the
`Federal Energy Regulatory Commission.
`
`The members of the SWC serve water to more than twothirds of California's vast
`population. The SWC members contract for water supplies with California
`Department of Water Resources, which operates and administers the SWP. The SWP
`captures and stores run off in northern California and delivers the water to
`areas of need in northern, central and southern California. Delivering this
`water requires significant electric energy resources for the pumping load.
`Indeed, the SWP is the largest single consumer of electricity in the State of
`California. Among other operating costs incurred by SWP, the SWC members pay
`all energy costs of the SWP, including costs of transmission and related service
`stemming from the California Independent System Operator Corporation
`(â(cid:128)(cid:156)CAISO â(cid:128)(cid:157))Controlled Grid. SWC thus has a compelling interest in EDF
`Renewables, Inc.â(cid:128)(cid:153)s ( â(cid:128)(cid:156)EDFR â(cid:128)(cid:157)) formal complaint and petition for declaratory
`order against Pacific Gas and Electric Company (â(cid:128)(cid:156)PG&E â(cid:128)(cid:157)).
`
`For the above reasons, SWC will be affected directly by the outcome of this
`proceeding. SWC claims an interest in this proceeding and a right to intervene
`to protect its interests as they may appear. SWCâ(cid:128)(cid:153)s participation in this case
`is necessary and appropriate to the administration of the Federal Power Act and
`will be in the public interest. SWCâ(cid:128)(cid:153)s interests will not be adequately
`represented by any other party. SWC, therefore, requests the Commission grant
`its Motion to Intervene, pursuant to Rules 212 and 214 of FERCâ(cid:128)(cid:153)s Rules of
`
`
`
`Practice and Procedure, 18 C.F.R. §§ 385.212 and 385.214 (2018), and make SWC
`a party to this proceeding for all purposes.
`
`The persons to whom correspondence, pleadings, and other papers in relation to
`this proceeding should be addressed and the persons whose names are to be placed
`on the Commissionâ(cid:128)(cid:153)s official service list are designated as follows pursuant
`to Rule 203, 18 C.F.R. § 385.203 (2018):
`
`Timothy Haines
`Stefanie Morris
`State Water Contractors
`1121 L Street, Suite 1050
`Sacramento, CA 95814
`(916) 4477357 (tel)
`thaines@swc.org
`smorris@swc.org
`
`Michael Postar
`Bhaveeta K. Mody
`Duncan, Weinberg, Genzer
`& Pembroke, P.C.
`1667 K Street, NW, Suite 700
`Washington, DC 20006
`(202) 4676370 (tel)
`(202) 4676379 (fax)
`mrp@dwgp.com
`bkm@dwgp.com
`
`SWC reserves the right to posit and address any issue that it or others may
`identify or raise herein that are developed before or after discovery or during
`the course of any hearing or technical or settlement conference that may be
`conducted in this proceeding.
`
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